1.1. Bolt Talent Solutions Ltd (we, us, our and Bolt) is a recruitment agency company which makes use of Artificial Intelligence capabilities to ensure that employers, have access to the latest skills available within their respective markets, and candidates have access to job positions which are relevant to their respective areas of practice, and which also provides sponsorship services (“Services”) on the Bolt Home Mauritius mobile application and/or website at www.bolttalent.com (the “Applications”).
1.2 We take privacy and security of personal data very seriously and we are committed to ensuring that we safeguard the privacy and personal data of the users (you, your, yourselves and Users) of the Applications, namely:
1.2.1. those who apply for any roles advertised or promoted by Bolt on behalf of its Clients (the “Candidates”);
1.2.2. those, other than Candidates, who retain the Services of Bolt (the “Clients”); and
1.2.3. those who visit the Applications (the “Visitors”).
1.3.1. who we are;
1.3.2. what personal information we collect about you;
1.3.3. how, when and why we collect, store, use, share and process your personal data;
1.3.4. how we keep your personal data secure;
1.3.5 for how long we keep your personal data;
1.3.6. your rights in relation to your personal data; and
1.3.7. how to contact us or the relevant supervisory authority should you have a complaint.
1.5. Bolt acts a Controller, as defined by the Data Protection Act 2017 (the “DPA”), with respect to the Users.
Section 1: Privacy of Candidates;
Section 2: Privacy of Clients; and
Section 3: Privacy of Visitors.
2. Section 1: Privacy of Candidates
2.1. What kind of personal data do we collect?
2.1.1. Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and interests:
22.214.171.124. Age/date of birth;
126.96.36.199. Employment history;
188.8.131.52. Emergency contacts and details of any dependants;
184.108.40.206. Referee details;
220.127.116.11. Immigration status (whether you need a work permit);
18.104.22.168. Nationality/citizenship/place of birth;
22.214.171.124. Start date or availability date;
126.96.36.199. A copy of your driving licence and/or passport/identity card;
188.8.131.52. Bank details;
184.108.40.206. Financial information (where we need to carry out financial background checks);
220.127.116.11. Tax Account Number (or equivalent in your country) and any other tax-related information;
18.104.22.168. Diversity information (racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information);
22.214.171.124. Sexual orientation;
126.96.36.199. Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our Applications or from links clicked on in emails from us;
188.8.131.52. Extra information that you choose to tell us;
184.108.40.206. Extra information that your referees choose to tell us about you;
220.127.116.11. Information about the services we provide to you;
18.104.22.168. Your account details, such as username and login details;
22.214.171.124. Your IP address, the browser you use, your operating system;
126.96.36.199. The pages of our Applications, or other resources on the Application, that you have accessed and when you accessed them;
188.8.131.52. Details of any documents or other resources that you have downloaded from or uploaded on the Applications.
Please note that:
2.1.2. the list at 2.1.1 above is not exhaustive.
2.1.3. it is important that the personal data that we hold about you is accurate and current. For this reason, you are hereby kindly requested to keep us informed in the event that your personal details change during your contractual relationship with us.
2.2. How do we collect your personal data?
2.2.1. We collect Candidates’ personal data in the following ways:
184.108.40.206. Personal data that you, the Candidates, give to us;
220.127.116.11. Personal data that we receive from other sources; and
18.104.22.168. Personal data that we collect automatically.
2.2.2. Personal data you give us
22.214.171.124. Bolt needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
126.96.36.199. There are numerous ways in which you can share your information with us, depending on what suits you. These may include:
-1. Entering your details on the Applications as part of the registration process;
-2. Leaving a hard copy CV at Bolt’s recruitment event, job fair or office;
-3. Emailing your CV or other information to Bolt Consultants or during an interview with them;
-4. Applying for jobs through a job aggregator, which then redirects you to the Applications;
-5. Entering a competition through a social media platform such as Facebook or Twitter (or similar).
2.2.3. Personal data we receive from other sources
188.8.131.52. We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
-1. Your referees may disclose personal information about you;
-2. Clients may share personal information about you with us; and
-3. If you ‘like’ our page on Facebook or ‘follow’ us on Twitter (or similar) we may receive your personal information from these sites.
2.2.4. Personal data we collect automatically
184.108.40.206. To the extent that you access our Applications or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically through the use of ‘cookies’ (see the section on ‘Cookies’ below).
2.3. How do we use your personal data
2.3.1. The DPA requires that we only use your personal data for the purposes for which it was collected, or where we have lawful justification for using it. Such justification includes the following:
220.127.116.11. Where you have given express informed consent to the use of your personal data for one or more specific purposes;
18.104.22.168. Where the use is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract;
22.214.171.124. Where the use is necessary for compliance with a legal obligation that we are subject to;
126.96.36.199. Where the use is necessary to protect your vital interests or those of another person;
188.8.131.52. Where the use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us;
184.108.40.206. Where the use is necessary for the purposes of our legitimate interest or those of a third party, except where those interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where you or the relevant person is a child; and
220.127.116.11. Where the use is necessary for the purpose of historical, statistical or scientific research.
2.3.2. We use personal data of Candidates for the following purposes:
18.104.22.168. Recruitment Activities;
22.214.171.124. Marketing Activities;
126.96.36.199. Equal Opportunities Monitoring;
188.8.131.52. To help us establish, exercise or defend legal claims; and
184.108.40.206. In appropriate circumstances, for Profiling, as defined in the DPA.
2.3.3. With respect to Recruitment Activities, your data is processed in the following instances:
220.127.116.11. Providing you with our recruitment services and to facilitate the recruitment process;
18.104.22.168. Assessing data about you against vacancies which we think may be suitable for you;
22.214.171.124. Sending your information to Clients, in order to apply for jobs and/or to assess your eligibility for jobs;
126.96.36.199. Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest for you;
188.8.131.52. Allowing you to participate in the interactive features of our Services;
184.108.40.206. Carrying out our obligations arising from any contracts entered into between us;
220.127.116.11. Carrying out our obligations arising from any contracts entered into between Bolt and third parties in relation to your recruitment;
18.104.22.168. Carrying out customer satisfaction surveys;
22.214.171.124. Verifying details you have provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
126.96.36.199. Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you; and
188.8.131.52. Carrying our assessment and development activities (such as psychometric evaluations or skills tests).
Note: The above non-exhaustive data processing instances rely upon the performance of the contractual relationship between us and the steps needed to deliver Services thereunder or your express informed consent.
2.3.4. With respect to Marketing Activities:
184.108.40.206.We will periodically send you information that we think you may find interesting. In particular, we may use your data in the non-exhaustive list of instances set out below, in accordance with any local laws and requirements:
-1. To market our full range of recruitment services to you;
-2. To enable us to develop and market other products and services;
-3. To send you details of reports, promotions, offers, networking and Clients’ events and general information about the industry sectors which we think might be of interest to you; and
-4. To display promotional excerpts from your details on the Applications as a success story (only where we have obtained your expressed consent to do so).
Note: Processing of your personal data for marketing activities generally relies on your express informed consent.
2.3.5. With respect to Equal Opportunities Monitoring:
220.127.116.11. We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data that we will collect from you are under the umbrella of “diversity information”. This can be information about your ethnic background, gender, disability, sexual orientation, religion or other similar beliefs and/or social-economic background. This diversity information is what we call “special category” data and slightly stricter data protection rules apply to it.
18.104.22.168. Where appropriate and in accordance with local laws and requirements, we will use this information on an anonymised basis to monitor our compliance with our equal opportunities obligations. We will also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Employer specifically requests such information to enable them to comply with their own employment processes.
22.214.171.124. We may also collect further “special category” personal data about you in terms of your medical health data and/or religious affiliation in order to make reasonable adjustments during the recruitment process.
126.96.36.199. Where required, we may also be called upon to collect details of any criminal convictions that you may have in order to assess your suitability for the job position(s).
Note: The processing of your personal data for Equal Opportunities Monitoring, especially when such data is “special category” data, relies on your express informed consent.
2.3.6. With respect to establishing, exercising or defending legal claims:
188.8.131.52. Where it is necessary for us to do so in order to establish, exercise or defend a legal claim, whether in court proceedings or in an administrative or out-of-court procedure. This processing generally relies upon factors related to our legitimate interests in processing the data.
2.3.7. With respect to Profiling:
184.108.40.206. Profiling is defined in the DPA as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.”
220.127.116.11. Profiling helps us to get a better idea of what you are like and your interests, likes and dislikes, all of which enable us to provide the best possible service to you.
18.104.22.168. We may use profiling for:
-1. Shortlisting and ranking of Candidates in order to be able to place you and other suitable Candidates on shortlists for particular roles based on prescribed criteria, which will allow our consultants to identify the most appropriate Candidates for roles more efficiently and also to recommend roles to you based on how your interests, habits, attributes and/or preferences rank in comparison to other Candidates.
-2. Automated decision making by making use of Artificial Intelligence systems to analyse data we have about you and other Candidates.
Note: The processing of personal data for profiling may be done on the basis of your express informed consent and/or on the basis that it is necessary for the performance of the contractual relationship between us and the steps needed to deliver Services.
2.4. Retention of data
2.4.1. Bolt will retain your data for as long as you have a Bolt Account, or to comply with our legal obligations, resolve disputes or enforce our agreements. However, we do reserve the right to delete inactive accounts after three (3) years, which would result in the deletion of all data. Deleting or cancelling your account on the Applications will cause all the data in the account to be permanently deleted.
2.5 Your rights with respect to your data
2.5.1. For more information on the rights you have, please see the section “Rights of data subjects” below.
3. Section 2: Privacy of Clients
3.1. What kind of personal data do we collect
3.1.1. Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to offer tailored Services to you:
22.214.171.124. Your contact details;
126.96.36.199. The contact details of individual contacts at your organisation/firm/company/society;
188.8.131.52. Your bank account and/or other financial details;
184.108.40.206. Details of any feedback you give us, and this may be by phone, email or post;
220.127.116.11. Information about the Services we provide to you;
18.104.22.168. Your IP address, the browser you use, your operating system;
22.214.171.124. The pages of our Applications, or other resources on the Applications, that you have accessed and when you accessed them; and
126.96.36.199. Such other data as may be required, in the circumstance, for Know Your Client (KYC) purposes.
3.2. How do we collect your personal data?
3.2.1. We collect Clients’ personal data in the following ways:
188.8.131.52. Personal data that you, the Clients, give to us;
184.108.40.206. Personal data that we receive from other sources; and
220.127.116.11. Personal data that we collect automatically.
3.2.2. Personal data you give us
18.104.22.168. Bolt needs to know certain information about you before onboarding you, in order to provide a tailored service and to ensure our relationship runs smoothly.
22.214.171.124. These data are collected directly from you in person, via email, via telephone and such other means of communication.
3.2.3. Personal data we receive from other sources
126.96.36.199. We also receive personal data about Clients from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
– 1.Clients, other than you, may share personal information about you with us;
– 2. Authorities may share personal information about you with us; and
– 3. Individuals may share personal information about you with us.
3.2.4. Personal data we collect automatically
188.8.131.52.bTo the extent that you access our Applications or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically through the use of ‘cookies’ (see the section on ‘Cookies’ below).
3.3. How do we use your personal data
3.3.1. The DPA requires that we only use your personal data for the purposes for which it was acquired, or where we have lawful justification for using it. Such justification includes the ones set out at paragraphs 184.108.40.206 to 220.127.116.11 above.
3.3.2. We generally process personal data of Clients in the following instances:
18.104.22.168. In order to supply our Services to you through our Applications. This processing relies upon the performance of the contractual relationship between us and the steps needed to deliver the Services.
22.214.171.124. To prevent or detect fraud, either against you or against any other person involved in any matter in which you are involved. This will help to prevent any damage either to you, a third party or to us. This processing relies upon factors related to our legitimate interests in processing the data.
126.96.36.199. To preserve the confidentiality of commercially sensitive information, and for our legitimate interests or those of a third party in relation to the protection of our, or another’s, intellectual property and other commercially valuable information. This processing relies upon your consent where this has been given, or upon factors related to our legitimate interests in processing the data in that we are seeking to monitor the Services we provide.
188.8.131.52. To improve the operation of our Applications and provide those Services which you have requested us to provide. This may include taking such security measures as are appropriate, backing up the data we hold, and contacting you. This processing relies upon your consent where this has been given, or upon factors related to our legitimate interests in processing the data in that we are seeking to provide Services as part of our business, or the performance of a contract between us, and the steps needed to deliver those contractual services.
184.108.40.206. For dealing with an enquiry submitted by you to us in connection with our Services. This processing relies upon your consent where this has been given, or upon factors related to our legitimate interests in processing the data in that we are seeking to provide services as part of our business, or the performance of a contract between us, and the steps needed to deliver those contractual services.
220.127.116.11. Where it is necessary for us to do so in order to establish, exercise or defend a legal claim, whether in court proceedings or in an administrative or out-of-court procedure. This processing relies upon factors related to our legitimate interests in processing the data.
18.104.22.168. In connection with the compliance by us with a legal obligation that we are subject to, or in order to protect your, or our vital interests, or the vital interests of another natural person.
3.4. Your rights with respect to your data
3.4.1. For more information on the rights you may have, please see the section “Rights of data subjects” below.
3.5. Retention of data
3.5.1. We undertake to keep your data for no longer than is necessary for the purposes for which it was collected.
4. Section 3: Privacy of Visitors
4.1. The Personal data we collect from you
4.1.1. We may receive and store certain types of information whenever you interact with our Applications. Generally, our Applications may automatically collect usage information, such as the numbers and frequency of visitors to our Site and its components.
4.2. The purpose for which personal data is collected
4.2.1. Bolt may automatically collect information such as your IP address, where you are based, the type and version of the browser you use, details of your operating system, how you came to our Applications (for example whether you were referred from another website or from a search engine), how long you remained on our Applications, the number of pages on our Applications that you viewed, how you moved around our Applications, the links you followed, and whether any of those links were used to leave our Applications.
4.2.2. We process personal data about you where you have provided express informed consent for same or for our legitimate interests of improving Services experience and developing new Services features, as well as for compliance purposes.
4.2.3. Where you have consented, we may use your contact information, for instance, to respond to your enquiries.
4.2.4. We use information about how you use the Applications and/or Services to improve our Services for all Users. This may include performing analysis aimed at improving the Services and making the Applications more user friendly by reducing the need for you to repeatedly enter the same information. We use device data and log data, for instance, to troubleshoot, to create new services, features and contents. We also infer your geographic location based on your IP address. We generally only use this data in aggregate form, that is, as a statistical measure and not in a manner that would identify you personally.
4.2.5. We may also use your personal information to the extent necessary for legitimate purposes, the performance of contracts and fulfilling legal obligations.
4.2.6. In all cases, we have undertaken to ensure that we place clear limitations on each use of your personal information so that your privacy is respected and only the information necessary to achieve certain legitimate interests is used.
4.3. Your rights with respect to your data
4.3.1. For more information on the rights you may have, please see the section “Rights of data subjects” below.
4.4. Retention of data
4.4.1. We undertake to keep your data for no longer than is necessary for the purposes for which it was collected.
5. Who do we share your data with
5.1. Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various legitimate reasons, with the following categories of people:
5.1.1. Any of our group companies;
5.1.2. Relevant employees within Bolt (this may include employees in overseas offices);
5.1.3.Relevant authorities, where we believe in good faith that the law or other regulation requires us to share the data;
5.1.4. Third party service providers who perform functions on our behalf;
5.1.5. Marketing technology platforms and suppliers; and
5.1.6. In the case of Candidates to:
22.214.171.124. potential Clients and other recruitment agencies/organisations to increase your chances of finding employment;
126.96.36.199. third parties who we have been retained to provide services such as reference, qualification and criminal convictions checks; and
188.8.131.52. third parties helping us by developing services and processes to optimise the Candidates selection process in order to improve the quality and efficiency of recruitment services.
6. Security and Safeguards
6.2. The personal information that we collect is securely stored within our database. We use standard, industry-wide practices such as firewalls and encryptions for protecting your information. Moreover, we regularly monitor our systems for possible vulnerabilities and attacks.
6.3. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the internet. We therefore recommend that you do not disclose your password to anyone.
7. Rights of data subjects
7.1. The DPA gives you, the data subject, various rights in relation to your personal data that we hold and process. These rights are exercisable without charge, and we are subject to specific time limits in terms of how quickly we must respond to you. Those rights are as follows:
7.1.1. Right to access: The right to obtain from us confirmation as to whether or not personal data concerning you is being processed and, where that is the case, access to that personal data and various other information, including the purpose for the processing, with whom the data is shared, how long the data will be retained and the existence of various other rights (see below).
7.1.2. Right to rectification: The right to obtain from us, without undue delay, the setting right of inaccurate personal data concerning you.
7.1.3. Right to erasure: Your right to request that, in certain circumstances, we delete data relating to you.
7.1.4. Right to object: The right, in certain circumstances, to object to your personal data being processed by us.
7.2. Full details of these rights can be found at Part VII of the DPA.
7.3. These rights are not absolute and should be reasonably exercised.
7.4. In response to a request, we will ask you to verify your identity, if we need to and to provide information that helps us to understand your request better. We will respond to your request within a reasonable time. If we do not comply with your request, whether in whole or in part, we will explain why.
7.5. In order to exercise your rights, please contact us at [email protected]
8. Our Cookies Policy
8.1 Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognise your browser and tell us how and when pages in the Applications are visited and by how many people. Our Applications may use session cookies, which track your browser session. These do not store any information on your computer but merely allow our Applications to recognise certain specificities of your usage, including whether you are logged in to your account.
8.2. Bolt cookies do not combine information collected through cookies with other personal information to tell us who you are or what your screen name or e-mail address is.
9. Safety of Minors below 16
9.1. Our Applications are not intended for and shall not be used by a minor below 16 years old (Child). Bolt does not knowingly collect and process personal data of a Child. During registration process for a Bolt account, if a User identifies himself/herself as a Child then Bolt will block such User from providing personal data.
9.2. If it comes to our attention that we have collected personal data from a Child, we may delete this information without notice. If you have reason to believe that this has occurred please contact us at [email protected]
11.2 If Bolt is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell the Services to you.
12. Law & Jurisdiction
13. Invalid Provisions
14. Making a complaint
14.1 If you have any issues as to the collection, acquisition, use, storage, disposal or processing of any personal data relating to you please contact us by addressing an email to [email protected] or by calling us on [+230 460 6666]
14.2 Notwithstanding our best efforts, inevitably sometimes things do go wrong. If you are unhappy with any aspect of the use and/or protection of your personal data, you have the right to make a complaint to the Data Protection Commissioner by:
14.2.1 duly filling and signing the complaint form (available at: https://dataprotection.govmu.org/Documents/Take%20Action/QMS7_complaint.pdf) and the declaration form (available at: https://dataprotection.govmu.org/Documents/Take%20Action/QMS8_Declaration.pdf); and
14.2.2 delivering same to “The Data Protection Commissioner, Data Protection Office, 5th Floor, SICOM Tower, Wall Street, Ebène, Mauritius.”